Analysis of Whistleblower Protection Laws

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Algeria – Whistleblowing Protection, Overview

Algeria has no specific whistleblowers protection besides scarce protection for civil servants contained in the 26 February 2006 Law 06-01 on the prevention of and fight against corruption (the Corruption law). The Corruption Law protects both private and public employees in their capacity as witnesses, experts, denunciators or victims from acts of vengeance, or intimidation in any form.

Egypt – Whistleblowing Protection, Overview

There is no specific law protecting whistleblowers, nor is there any protection for whistleblowers within law enforcement agencies. Whistleblowing protection afforded to civil servants is non-existent.

Libya – Whistleblowing Protection, Overview

Currently in Libya, there is virtually no regulation regarding whistleblowing for both the public and the private sectors. Libya has passed a specific anti-corruption law but there is no law guaranteeing the protection of whistleblowers. Access to information is generally limited in Libya.

Mauritania – Whistleblowing Protection, Overview

In Mauritania, there are no laws in place protecting whistleblowers besides a few places in the constitution. A well needed regulatory framework to ensure that there are no violations of the constitution is not in place. There is no governmental transparency and it is doubtful whether this will change in the foreseeable future.

Morocco – Whistleblowing Protection, Overview

Although more focused on witness protection, the Moroccan parliament has passed a law aimed at protecting ‘corruption’ whistleblowers as well as expert witnesses in trials and their families. Morocco was the first Arab country to introduce a constitutional provision securing the right to access of information. In March of 2013, the government published a draft law regarding freedom of information.

South Africa – Whistleblowing Protection

Legislation particularly aimed at protecting whistleblowers exists today through the Constitution of the Republic of South Africa, the Public Disclosure Act 26 of 2000, the Promotion of Access to Information Act 2 of 2000, the Labour Relations Act 66 of 1995 and the Companies Act 71 of 2008. The Public Disclosure Act protects whistleblowers in the public and the private sector from retribution.

Sudan – Whistleblowing Protection, Overview

Tunisia – Whistleblowing Protection, Overview

The government has adopted a decree on access to public documents following the 2011 revolution. Whistleblowing protection in Tunisia is minimal – there is no whistleblower protection for civil servants, but for private sector employees. Tunisia passed a law on the Right of Access to Information in 2011.

Bahrain – Whistleblowing Protection, Overview

There are no mechanisms in place for the protection of whistleblowers. There is a general lack of information regarding whistleblowers and to whom they can report with the exception of the banking sector. No legal framework guarantees freedom of information.

Iraq – Whistleblowing Protection, Overview

In Iraq the whistleblowing protection mechanism in place are minimal. There is no specific law protecting whistleblowers or dealing with whistleblowing. A law that provides rewards for informants is in place. It is still too early to identify institutions that may implement whistleblower protection.

Jordan – Whistleblowing Protection, Overview

In Jordan, there is virtually no regulation covering whistleblowers or whistleblowing in both the private and the public sector besides the confidentiality of submitted information in the public sector. Whistleblowing as a concept is comparatively unknown. In Jordan, an ‘access to information’ law was passes in 2007, the first of its kind in the Arab region. However, there are few limitations due to its vagueness, and its relationship with the larger legal framework.

Kuwait – Whistleblowing Protection, Overview

In Kuwait, there is no specific protection for whistleblowers but some arbitrary and seldom used mechanisms are in place. These mechanisms are ultimately not intended to protect whistleblowers per se. A draft law aimed at protecting whistleblowers awaits parliamentary approval.

Kyrgyzstan – Whistleblower Laws

Lebanon – Whistleblowing Protection, Overview

There is no legislation guaranteeing the right to access public information or protection for whistleblowers. Since 2000, Lebanon has witnessed several attempts by media and legal activists to have the Lebanese parliament pass a law on access to information. But these efforts have not yet materialized. In June 2010, the National Network for the Right of Access to Information (NNRAI) submitted a bill proposal on whistleblower protection to Parliament. The bill covers the public and private sectors.

Palestine – Whistleblowing Protection, Overview

There is no effective or well-functioning legislation aimed at protecting whistleblowers. The Anti-Corruption Commission has prepared a draft law for the protection of witnesses and whistleblowers. News regarding the implementation of such law is not publicly available.

Syria – Whistleblowing Protection, Overview

Currently, in Syria there is no legislation in place that guarantees the protection of whistleblowers. Journalists that report on corruption are subjected to severe harassment and intimidation. There is no legislation that establishes the right to access to information.

Belgium – Whistleblower Laws

Bulgaria – Whistleblower Laws

Croatia – Whistleblower Laws

Cyprus – Whistleblower Protection

Czech Republic – Whistleblower Protection

Denmark – Whistleblower Protection

Denmark has no current or proposed whistleblower legislation, and no statutory provisions to protect whistleblowers from retaliation. Section 77 of the Constitution grants freedom of speech to all people. However, many laws limit this freedom in the workplace.

Germany – Whistleblower Protection

Greece – Whistleblower Protection

Hungary – Whistleblower Protection

Ireland – Whistleblower Protection

Italy – Whistleblower Protection

Latvia – Whistleblower Protection

Latvia lacks comprehensive legal and practical mechanisms to protect and support whistleblowers. The Labor Law bans retaliation against public and private sector employees who report crimes or administrative violations in the workplace to government authorities. Employers, however, not government regulators, are primarily responsible for compliance with the law.

Lithuania – Whistleblower Protection

Lithuania still lacks a comprehensive system to protect whistleblowers from retaliation. The only legal provision related to whistleblowing is a 2003 resolution that allows financial compensation for citizens who provide information on financial crimes. Under certain circumstances, employees are protected from unfair dismissal, but whistleblowing is not particularly taken into account.

Luxembourg – Whistleblower Protection

Luxembourg’s main provision to protect people who report crime and misconduct from retaliation is the Law on Strengthening the Means to Fight Corruption. The law includes various international standards, including coverage for public and private sector employees, a range of disclosure channels, and the requirement that employers prove any action taken against an employee is not linked to whistleblowing.

Malta – Whistleblower Protection

Netherlands – Whistleblower Protection

The House for Whistleblowers Act, which took effect on 1 July 2016, established a House for Whistleblowers where public and private sector employees can report regulatory violations, health and environmental risks, and threats to the functioning of public services or companies. The law bans retaliation if an employee had a reasonable belief the report was accurate. Analyses of the law suggest that victimized employees must seek remedies in the courts, which historically do not have a good record on compensating whistleblowers.

Norway – Whistleblower Laws

Norway has specific legislation for the protection of whistleblowers. The Norwegian legislation affords employees a statutory right to notify wrongdoing as well as requiring employers to develop internal reporting procedures.

Poland – Whistleblower Protection

Poland lacks effective legal mechanisms to protect whistleblowers from retaliation in the workplace. Laws including the Labor Code, Criminal Code and the Code of Criminal Procedure tangentially address whistleblowing, though they were not specifically enacted to protect whistleblowers. Labor laws include employee protection from unjust dismissals, but problems can arise if a victimized whistleblower takes their case to court.

Portugal – Whistleblower Protection

Portugal has among the weakest legal protections for whistleblowers in Europe. The only known legal provision in Portugal that offers any protection for whistleblowers is one brief article in Law 19/2008 which states that employees who report crimes cannot be “harmed”. No type of disclosure or protection system is established, and the article does not explain how whistleblowers can be compensated for reprisals or how their identity is protected. Protection from disciplinary actions is limited to one year, and the mechanisms for ensuring this are unclear.

Romania – Whistleblower Protection

Romania’s “Law on the Protection of Public Officials Complaining about Violations of the Law” covers most employees in the public sector. It allows employees to report a wide range of crimes and be protected from retaliation. Though the law is widely considered to be strong on paper, the number of reported cases is relatively low, suggesting weak implementation. There are no specific protections for employees in the private sector.

Russia – Whistleblowing Protection

In Russia, legislation ensuring the protection of whistleblowers is non-existent. However, legal protection for victims and witnesses exists. Corporate whistleblowers are virtually not protected by law. Whilst there is no specific legislation related to whistleblowers in Russia, general protection mechanisms in relation to freedom of expression and information are available.

Slovakia – Whistleblower Protection

Slovenia – Whistleblower Protection

Slovenia’s Integrity and Prevention of Corruption Act provides near-comprehensive protections to employees who report crime and corruption. Some observers, however, claim the law remains poorly enforced and that the commission that oversees its implementation remains weak. Under the law, the burden lies with the employer to prove that any measures taken against an employee were not linked to the employee having reported wrongdoing. Whistleblowers are granted protection if they act in good faith. The law covers employees in both the private and the public sectors, and allows anonymous reporting.

Spain – Whistleblower Protection

There is no specific law on whistleblower protection for employees in Spain, and current legislation only indirectly refers to whistleblowing.While all Spanish citizens technically are obliged to report criminal activities to the relevant authorities, they must personally come forward in order for their claim to be investigated. The lack of protective mechanisms is seen by many as a deterrent in complying with this obligation. The only legislative regulation loosely related to whistleblowing is a provision allowing citizens to anonymously report conflicts of interest of high-ranking officials and members of Parliament. Witnesses in criminal proceedings may receive protection.

Sweden – Whistleblower Protection

In 2016 Sweden became the first Scandinavian country to pass a dedicated whistleblower protection law. The law seeks to standardize whistleblowing and free speech rights granted in other policies. Though a significant improvement, the new law lacks many best practices and omits some recommendations put forth during an official inquiry.

Turkey – Whistleblowing Protection

Turkey lacks legislation to protect whistleblowers. In Turkey whistleblower protection is often confused with witness protection laws, however the Witness Protection Law in Turkey does not offer protection to whistleblowers or journalists who publish stories. There are no regulations that prevent legal entities from adopting internal whistleblowing regulation as part of their policies and procedures.

United Kingdom – Whistleblower Protection

Australia – Whistleblowing Protection, Overview

Australia whistleblower protection laws are complex and spread out. All jurisdictions have stand-alone acts that provide for the establishment of whistleblowing systems. The Public Interest Disclosure Act 2013 is the latest piece of legislation and the first at Federal level aimed at facilitating the reporting of wrongdoing by public officials in the Commonwealth public sector and providing protection to public officials who make qualifying public interest disclosures.

Chile – Whistleblower Protection, Overview

1. Background Chile ranked 22nd on the 2013 Transparency International Corruption Perceptions Index with a score of 71 out of 100 (where 100 is very clean and 1 is very corrupt). Chile currently lacks comprehensive whistleblower laws or legal provisions to protect whistleblowers from retaliation in either the public or private sectors. The only relevant […]

Ecuador – Whistleblowing Protection

Formal protection for whistleblowers exists mainly in anti-corruption legislation, but cases of whistleblowing leading to investigations and prosecutions are rare. Constitutional and legal provisions to ensure government transparent and public access to information exist but getting access is difficult in practice as there is uneven compliance and some confusion over the application of the law.

Peru – Whistleblowing Protection

In 2010, Peru passed specific whistleblower legislation to protect public sector employees. The Whistleblower Protection law affords protection from dismissal, confidentiality in reporting acts of corruption and compensation for the whistleblower. There is no legal framework protecting whistleblowers in the private sector.

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